This conflict-of-interest policy applies to each entity of the Access Capital Partners, each staff, each client, third party and investor, all activities and investment services provided.
A conflict-of-interest situation arises from any situation where two or more parties have divergent interests when involved in any given situation. It takes into account any situation when Access Capital Partners or any relevant person is likely to make a financial gain or avoid a financial loss, has a professional or personal interest in the outcome of a service provided to the Fund/ Portfolio and its investors’ which is distinct from the Fund/ Portfolio’s interest in that outcome. A situation of potential conflict of interest may arise even when there is no apparent or obvious improper or unlawful act or disadvantage to a client or an investor.
PREVENTION
The reputation and development of Access Capital Partners is founded on its operational excellence in generating performance and its rigorous commitment to respect ethical principles in all dealings. Activities and investment services are carried out with competence, care, diligence, loyalty, integrity and fairness with the best interests of each client and investor in mind at all times.
Access Capital Partners and its managing partners promote a culture of self-awareness in ethics and conflicts of interest. It has established internal codes and procedures and implemented adequate processes to prevent any conflict of interest from arising.
Those include, without being limited to:
- Code of Ethics
- Employment contracts
- Employee trainings
- Information barriers
- Segregation of duties
- Whistleblowing policy